Nigeria's Central Bank Regulates Open Banking Framework

Open Banking in Nigeria, regulated by the Central Bank of Nigeria (CBN), began with the issuance of the Regulatory Framework for Open Banking in February 2021. This framework established foundational principles and API standards, which were further operationalized through the CBN’s Operational Guidelines for Open Banking in 2023.

The article examines liability issues in Nigeria’s open banking ecosystem, particularly focusing on contractual relationships among banks, third-party service providers, and users. It highlights the necessity for user consent before data sharing and the obligations of banks and third-party providers under the Nigeria Data Protection Act.

The CBN Guidelines mandate that both parties must be registered on the open banking Registry and comply with security standards and data ethics. Despite the established regulatory framework, the article points out that the liability and dispute resolution architecture is underdeveloped, creating uncertainty and risks for banks, FinTech firms, and end-users.